Delay in filing the appeal against the intimation under section 143(1) was condoned because the assessee had pursued rectification and a reminder, and the time taken in that process was treated as beyond its control. Applying the principle of sufficient cause, the Tribunal held that limitation provisions should be construed liberally to advance substantial justice where there is no negligence, inaction or lack of bona fides. The order dismissing the appeal on limitation was set aside and the matter was restored for decision on merits. The connected appeal against the rectification order was dismissed as infructuous after restoration of the main appeal.
Delay in filing the appeal against the intimation under section 143(1) was condoned because the assessee had pursued rectification and a reminder, and the time taken in that process was treated as beyond its control. Applying the principle of sufficient cause, the Tribunal held that limitation provisions should be construed liberally to advance substantial justice where there is no negligence, inaction or lack of bona fides. The order dismissing the appeal on limitation was set aside and the matter was restored for decision on merits. The connected appeal against the rectification order was dismissed as infructuous after restoration of the main appeal.
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